Apple Inc.v.ContentGuard Holdings, Inc.

Patent Trial and Appeal Board

Jun 24, 2015

10956121 (P.T.A.B. Jun. 24, 2015)

Trials@uspto.gov Paper 9
571-272-7822 Entered: June 24, 2015

UNITED STATES PATENT AND TRADEMARK OFFICE
____________

BEFORE THE PATENT TRIAL AND APPEAL BOARD
____________

APPLE INC.,
Petitioner,

v.

CONTENTGUARD HOLDINGS, INC.,
Patent Owner.
____________

Case IPR2015-00351
Patent 7,774,280 B2
____________

Before MICHAEL R. ZECHER, BENJAMIN D. M. WOOD, and
GEORGIANNA W. BRADEN, Administrative Patent Judges.

ZECHER, Administrative Patent Judge.

DECISION
Denying Institution of Inter Partes Review
35 U.S.C. § 314(a) and 37 C.F.R. § 42.108

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I. INTRODUCTION
Petitioner, Apple Inc. (“Apple”), filed a Petition (“Pet.”) requesting an
inter partes review of claims 1–5, 8, 11–16, 19, 22, 24–28, 31, and 34 of
U.S. Patent No.7,774,280 B2 (“the ’280 patent,” Ex. 1001). Paper 1. Patent
Owner, ContentGuard Holdings, Inc. (“ContentGuard”), timely filed a
Preliminary Response (“Prelim. Resp.”). Paper 8.
We have jurisdiction under 35 U.S.C. § 314(a), which provides that an
inter partes review may not be instituted unless the information presented in
the Petition shows “there is a reasonable likelihood that the petitioner would
prevail with respect to at least 1 of the claims challenged in the petition.”
Taking into account the arguments presented in ContentGuard’s Preliminary
Response, we conclude that the information presented in the Petition does
not establish that there is a reasonable likelihood that Apple will prevail in
challenging claims 1–5, 8, 11–16, 19, 22, 24–28, 31, and 34 of the ’280
patent as unpatentable under 35 U.S.C. § 103(a). We, therefore, deny the
Petition.
A. Related Matters
The ’280 patent has been asserted in the following three district court
cases: (1) ContentGuard Holdings, Inc. v. Amazon.com Inc., No. 2:13-cv-
01112 (E.D. Tex.); (2) Google Inc. v. ContentGuard Holdings, Inc., No.
3:14-cv-00498 (N.D. Cal.); and (3) ContentGuard Holdings, Inc. v. Google
Inc., No. 2:14-cv-00061 (E.D. Tex). Pet. 1; Paper 7, 2. In addition to this
Petition, Apple filed at least seven other Petitions challenging the
patentability of a certain subset of claims in the following patents owned by
ContentGuard: (1) the ’280 patent (Cases IPR2015-00352, IPR2015-00353,
and IPR2015-00354); and (2) U.S. Patent No. 8,001,053 B2 (Cases
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IPR2015-00355, IPR2015-00356, IPR2015-00357, and IPR2015-00358).
Pet. 2; Paper 7, 1.
B. The ’280 Patent
The ’280 patent, titled “System and Method for Managing Transfer of
Rights Using Shared State Variables,” issued August 10, 2010, from U.S.
Patent Application No. 10/956,121, filed on October 4, 2004. Ex. 1001, at
[54], [45], [21], [22]. The ’280 patent is a continuation-in-part of U.S.
Patent Application No. 10/162,701, filed on June 6, 2002. Id. at [63]. The
’280 patent also claims priority to the following provisional applications:
(1) U.S. Provisional Application No. 60/331,624, filed on November 20,
2001; (2) U.S. Provisional Application No. 60/331,623, filed on November
20, 2001; (3) U.S. Provisional Application No. 60/331,621, filed on
November 20, 2001; (4) U.S. Provisional Application No. 60/296,113, filed
June 7, 2001; (5) U.S. Provisional Application No. 60/296,117, filed on June
7, 2001; and (6) U.S. Provisional Application No. 60/296,118, filed on June
7, 2001. Id. at [60].
The ’280 patent generally relates to a method and system for
managing the transfer of rights associated with digital works using shared
state variables. Ex. 1001, 1:18–20. According to the ’280 patent, one of the
most important issues impeding the widespread distribution of digital works
is the current lack of ability to enforce the rights of content owners during
the distribution and use of their digital works. Id. at 1:24–29. In particular,
content owners do not have control over downstream parties unless they are
privy to transactions with the downstream parties. Id. at 2:33–34.
Moreover, the concept of content owners simply granting rights to others
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that are a subset of the possessed rights is not adequate for multi-tier
distribution models. Id. at 2:45–48.
The ’280 patent purportedly addresses these problems by providing a
method and system for transferring rights associated with an item—
presumably a digital work—from a supplier to a consumer. Ex. 1001, 2:52–
55. The consumer obtains a set of rights associated with the digital work,
which includes meta-rights specifying rights that may be derived therefrom.
Id. at 2:55–57. If the consumer is entitled to the rights derived from the
meta-rights, the disclosed invention then derives at least one right from the
meta-rights. Id. at 2:58–60. The rights that may be derived from the meta-
rights include at least one state variable based on the set of rights, which, in
turn, may be used to determine a state of the derived right. Id. at 2:62–64.
C. Illustrative Claim
Of the challenged claims, claims 1, 12, and 24 are independent.
Claims 1, 12, and 24 are directed to a method, a system, and a device,
respectively, for transferring rights associated with an item from a rights
supplier to a rights consumer. Claims 2–5, 8, and 11 directly depend from
independent claim 1; claims 13–16, 19, and 22 directly depend from
independent claim 12; and claims 25–28, 31, and 34 directly depend from
independent claim 24. Independent claim 1 is illustrative of the challenged
claims and is reproduced below:
1. A computer-implemented method for transferring
rights adapted to be associated with items from a rights supplier
to a rights consumer, the method comprising:
obtaining a set of rights associated with an item, the set
of rights including a meta-right specifying a right that can be
created when the meta-right is exercised, wherein the meta-
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right is provided in digital form and is enforceable by a
repository;
determining, by a repository, whether the rights
consumer is entitled to the right specified by the meta-right; and
exercising the meta-right to create the right specified by
the meta-right if the rights consumer is entitled to the right
specified by the meta-right, wherein the created right includes
at least one state variable based on the set of rights and used for
determining a state of the created right.
Ex. 1001, 15:7–22.
D. Prior Art Relied Upon
Apple relies upon the following prior art references:
England US 6,327,652 B1 Dec. 4, 2001 Ex. 1009
(filed Jan. 8, 1999)
Gruse US 6,389,538 B1 May 14, 2002 Ex. 1008
(filed Oct. 22, 1998)
Ireton US 2002/0077984 A1 June 20, 2002 Ex. 1010
(filed Dec. 19, 2000)

E. Asserted Grounds of Unpatentability
Apple challenges claims 1–5, 8, 11–16, 19, 22, 24–28, 31, and 34 of
the ’280 patent based on the asserted grounds of unpatentability (“grounds”)
set forth in the table below. Pet. 3, 25–60.
Reference(s) Basis Challenged Claims
Ireton § 103(a) 1–5, 8, 11–16, 19, 22, 24–28, 31, and 34
Ireton and England § 103(a) 1–5, 8, 11–16, 19, 22, 24–28, 31, and 34
Ireton and Gruse § 103(a) 1–5, 8, 11–16, 19, 22, 24–28, 31, and 34

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II. ANALYSIS
A. Claim Construction
In an inter partes review, we construe claims by applying the broadest
reasonable interpretation in light of the specification. 37 C.F.R. § 42.100(b);
see In re Cuozzo Speed Tech., LLC, 778 F.3d 1271, 1281–82 (Fed. Cir.
2015) (“Congress implicitly adopted the broadest reasonable interpretation
standard in enacting the AIA,” and “the standard was properly adopted by
PTO regulation”); Office Patent Trial Practice Guide, 77 Fed. Reg. 48,756,
48,766 (Aug. 14, 2012). Under the broadest reasonable interpretation
standard, and absent any special definitions, claim terms are given their
ordinary and customary meaning, as would be understood by one of ordinary
skill in the art in the context of the entire disclosure. In re Translogic Tech.
Inc., 504 F.3d 1249, 1257 (Fed. Cir. 2007). Any special definitions for
claim terms or phrases must be set forth with reasonable clarity,
deliberateness, and precision. In re Paulsen, 30 F.3d 1475, 1480 (Fed. Cir.
1994).
Apple proposes constructions for numerous terms or phrases, some of
which are not recited explicitly in the challenged claims. Pet. 5–24. In
response, ContentGuard proposes alternative constructions for most of the
terms or phrases construed by Apple. Prelim. Resp. 18–33. For purposes of
this decision, we need only assess the constructions offered by the parties for
the claim term “repository” because our determination to deny the Petition is
based, at least in part, on the construction of this claim term.
Apple contends that the broadest reasonable interpretation of the
claim term “repository” is “a trusted system, which maintains physical,
communications and behavioral integrity, and supports usage rights using
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information that enables it to enforce both ‘meta-rights’ and ‘usage rights’
associated with a particular digital work.” Pet. 19 (citing Ex. 1003 ¶¶ 284–
89). Apple argues that the construction it offers for the claim term
“repository” in this proceeding is consistent with the construction of the
same claim term in previous inter partes review proceedings handled by
another panel of the Board, one of which involves U.S. Patent No. 5,634,012
(“Stefik”) that is incorporated by reference into the ’280 patent. See id. In
those proceedings, Apple asserts that the Board determined that the claim
term “repository” was defined explicitly as “a trusted system, which
maintains physical, communications and behavioral integrity, and supports
usage rights.” Id. (citing Ex. 1035, 9) (emphasis omitted). Apple also
asserts that, in those proceedings, the Board observed that to possess
“physical integrity,” the repository must, among other things, “prevent[]
access to information by a non-trusted system.” Id. (citing Ex. 1035, 11).
Although Apple does not address separately “communications
integrity” and “behavioral integrity” in its Petition, Apple’s declarant, Dr.
Atul Prakash, nonetheless addresses these aspects of the claim term
“repository” in his supporting testimony. Dr. Prakash testifies that, in
previous inter partes review proceedings before the Board, one of which
involved Stefik, the Board defined “communications integrity” as “only
communicates with other devices that are able to present proof that they are
trusted systems, e.g., by using security measures such as encryption,
exchange of digital certificates, and nonces.” Ex. 1003 ¶ 284 (citing
Ex. 1041, 12). Dr. Prakash further testifies that the Board defined
“behavioral integrity” as requiring “software to include a digital certificate
in order to be installed in the repository.” Id. (citing Ex. 1041, 13).
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With a few exceptions, ContentGuard generally agrees with Apple’s
proposed construction for the claim term “repository,” including its and Dr.
Prakash’s definitions of “physical integrity,” “communications integrity,”
and “behavioral integrity.” Prelim. Resp. 24–26. ContentGuard argues that
the claim term “repository” should be construed as “a trusted system in that
it maintains physical, communications, and behavioral integrity in the
support of usage rights.” Id. at 24 (emphasis added). ContentGuard argues
that its proposed construction is consistent with both the Board’s
construction of the claim term “repository” in the previous inter partes
review proceedings, which considered Stefik, and the construction adopted
by a district court for the ’280 patent. Id. at 24–25 (citing Pet. 19; Ex. 2001,
15, 99). ContentGuard urges us to adopt its proposed construction for
reasons specified by the district court. Id. at 25. ContentGuard further
argues that we should not adopt the language in Apple’s proposed
construction that characterizes a repository as enforcing both meta-rights and
usage rights because it would render the claim language describing a “meta-
right . . . enforceable by a repository” redundant. Id.
As an initial matter, we agree with the parties that the specification of
the ’280 patent does not provide an explicit definition for the claim term
“repository.” We also agree with the parties that the ’280 patent
incorporates by reference Stefik, which provides an explicit definition for
the claim term “repository.” Ex. 1001, 2:9–12; Ex. 1012, 53:23–27. Stefik
provides a glossary that explicitly defines the claim term “repository” as
“[c]onceptually a set of functional specifications defining core functionality
in the support of usage rights. A repository is a trusted system in that it
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maintains physical, communications and behavioral integrity.” Ex. 1012,
53:23–27.
With this glossary definition from Stefik in mind, we decline to adopt
the language in Apple’s proposed construction pertaining to “using
information that enables it to enforce both ‘meta-rights’ and ‘usage rights’
associated with a particular digital work.” It is well settled that our
reviewing court disfavors any claim interpretation that renders a claim term
or phrase superfluous. Stumbo v. Eastman Outdoors, Inc., 508 F.3d 1358,
1362 (Fed. Cir. 2007). We agree with ContentGuard that, if we were to
adopt this language proposed by Apple, it would render the claim phrase a
“meta-right . . . enforceable by a repository,” explicitly recited in
independent claims 1, 12, and 24, superfluous.
After reviewing the remaining language in the constructions offered
by both parties, we discern little, if any, difference between a “repository”
that is “a trusted system which maintains physical, communications, and
behavioral integrity, and supports usage rights,” and one that is “a trusted
system in that it maintains physical, communications, and behavioral
integrity in the support of usage rights.” Pet. 19; Prelim. Resp. 24
(emphases added). We view the Board’s construction of the claim term
“repository” in the previous inter partes reviews, which were brought
against ContentGuard patents that share a similar disclosure with Stefik
incorporated by reference in the ’280 patent, as informative. We give more
weight to the panel’s construction of the claim term “repository” in those
proceedings than the district court’s construction of the same claim term
primarily because this proceeding and the previous proceeding before the
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Board both apply the broadest reasonable interpretation standard to the
challenged claims of an unexpired patent. 37 C.F.R. § 42.100(b).
For purposes of this proceeding, we construe the claim term
“repository” as “a trusted system which maintains physical,
communications, and behavioral integrity, and supports usage rights.” We
further define “physical integrity” as “preventing access to information by a
non-trusted system”; “communications integrity” as “only communicates
with other devices that are able to present proof that they are trusted
systems, e.g., by using security measures such an encryption, exchange of
digital certificates, and nonces”; and “behavioral integrity” as “requiring
software to include a digital certificate in order to be installed in the
repository.”
B. Obviousness Based on Ireton
Apple contends that claims 1–5, 8, 11–16, 19, 22, 24–28, 31, and 34
are unpatentable under § 103(a) over Ireton. Pet. 24–45. Apple explains
how Ireton purportedly teaches the claimed subject matter of each
challenged claim (id. at 26–38), and relies upon the Declaration of
Dr. Prakash (Ex. 1003 ¶¶ 236–308, 343–53, 661–780)
1
to support its

1
Our governing statute and rules require a petitioner to set out their claim
challenges “with particularity” and with a “detailed explanation of the
significance of the evidence.” 35 U.S.C. § 312(a)(3); 37 C.F.R.
§§ 42.22(a)(2), 42.104(b)(4), (5). Likewise, the Office Patent Trial Practice
Guide admonishes a petitioner to “focus on concise, well organized, easy-to-
follow arguments supported by readily identifiable evidence of record.” 77
Fed. Reg. 48,756–73, 48,763 (Aug. 14, 2012). In general, citations to
voluminous sections, e.g., one hundred and nineteen paragraphs, of an expert
declaration do not conform to these requirements and guidance, and are
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positions (Pet. 24–25). We have considered Apple’s explanations and
supporting evidence, but we are not persuaded Apple has presented
sufficient evidence to support a finding that Ireton teaches the claimed
“repository” that exhibits “behavioral integrity.”
We begin our analysis with the principles of law that generally apply
to a ground based on obviousness, followed by a brief discussion of Ireton,
and then we turn to the parties’ arguments directed to the claimed
“repository” that exhibits “behavioral integrity.”
1. Principles of Law
A claim is unpatentable under § 103(a) if the differences between the
claimed subject matter and the prior art are such that the subject matter, as a
whole, would have been obvious at the time the invention was made to a
person having ordinary skill in the art to which said subject matter pertains.
KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 406 (2007). The question of
obviousness is resolved on the basis of underlying factual determinations,
including: (1) the scope and content of the prior art; (2) any differences
between the claimed subject matter and the prior art; (3) the level of skill in
the art; and (4) where in evidence, so-called secondary considerations.
Graham v. John Deere Co., 383 U.S. 1, 17–18 (1966). We analyze this
asserted ground based on obviousness with the principles identified above in
mind.

unhelpful. As such, citations of this type, as well as statements they
allegedly support, are not entitled to consideration.
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2. Ireton
Ireton generally relates to media content and, in particular, enabling
the sharing of protected digital media between playback devices. Ex. 1010
¶ 1. Figure 1 of Ireton, reproduced below, illustrates a block diagram of a
media system.

As shown in Figure 1 of Ireton, the system includes playback devices
105a and 105b, digital media servers 110a and 110b, and computers 115a
and 115b operatively coupled to one another via network 120. Ex. 1010
¶ 17. According to Ireton, this system allows a consumer of digital media to
access copies of the digital media in a number of locations without violating
prescribed usage rules associated with the digital media. Id. ¶ 19.
In one embodiment, Ireton discloses that each connection to a system
component is established with a secure authenticated channel (“SAC”).
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Ex. 1010 ¶ 34. A SAC is a mechanism for communicating digital data
between two system components over a connection that is secure by virtue
of the encrypted or otherwise decoded digital data. Id. Ireton discloses
using conventional encryption or encoding techniques, such as public-
private key encryption, to secure the communication channel. Id. ¶¶ 35, 50.
In addition, Ireton discloses that each component in the system may
verify or authenticate the identity of other components included in the
system. Ex. 1010 ¶ 34. This layer of security, in conjunction with security
provided by a SAC, prevents data from being copied illicitly, used, or
otherwise tampered with as it is transferred between devices. Id.
3. “Repository” That Exhibits “Behavioral Integrity”
Independent claim 1 recites, in relevant part, “wherein the meta-right
is provided in digital form and is enforceable by a repository,” and
“determining, by a repository, whether the rights consumer is entitled to the
rights specified by the meta-right.” Ex. 1001, 15:12–16 (emphases added).
Independent claims 12 and 24 recite similar limitations. Id. at 15:58–61,
16:40–43. By virtue of their dependence to at least one of independent
claims 1, 12, and 24, claims 2–5, 8, 11, 13–16, 19, 22, 25–28, 31, and 34
also require “a repository.”
In its Petition, Apple contends that Ireton’s digital media servers 110a
and 110b each constitute the claimed “repository.” Pet. 29–31. In
particular, Apple argues that Ireton’s digital media servers 110a and 110b
enforce usage rights associated with digital media by implementing an
outtake process that encrypts the digital media using conventional public-
private key encryption techniques. Id. at 30–31 (citing Ex. 1010 ¶¶ 35, 50;
Ex. 1003 ¶ 678, 689). Apple further argues that these techniques ensure that
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encrypted digital files and the usage rights associated therewith only may be
accessed by components of Ireton’s system that have the necessary private
key. See id. at 31. Apple, therefore, asserts that Ireton’s digital media
servers 110a and 110b exhibit “behavioral integrity.” Id. (citing Ex. 1003
¶ 681).
In response, ContentGuard contends that Apple fails to demonstrate
that Ireton’s digital media servers 110a and 110b each constitute the claimed
“repository” that exhibits “behavioral integrity.” Prelim. Resp. 44.
ContentGuard argues that “behavioral integrity” was defined by both a
previous panel of the Board and a district court to require “software to
include a digital certificate in order to be installed in the repository.” Id.
(citing Ex. 1041, 13; Ex. 2001, 19–21). ContentGuard further argues that
Apple’s reliance on Ireton’s conventional public-private key encryption
techniques to prevent unauthorized access to stored content has no bearing
on “behavioral integrity” as previously defined by the Board and the district
court because it does not ensure that software is trusted before being
installed on Ireton’s digital media servers 110a and 110b. Id. ContentGuard
also argues that the supporting testimony of Dr. Prakash should be entitled to
little, if any, weight because his definition of “behavioral integrity” does not
comport with how the same term was defined by both the previous Board
panel and the district court. Id. at 44–45 (citing Ex. 1003 ¶ 681).
As we explained in the claim construction section, we construe
“repository” as “a trusted system which maintains physical,
communications, and behavioral integrity, and supports usage rights.” See
supra Section A. Of particular importance in this case is our definition of
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“behavioral integrity” as “requiring software to include a digital certificate
in order to be installed in the repository.” Id.
We agree with ContentGuard that Ireton’s digital media servers 110a
and 110b each do not constitute a claimed “repository” that exhibits
“behavioral integrity” because the private key used by these digital media
servers to access or decrypt the encrypted digital files, and the usage rights
associated therewith, does not constitute a digital certificate. Apple does not
direct us to, nor can we find, a disclosure in Ireton that contemplates using
the private key to perform the same function as a digital certificate—namely,
to authenticate the source of the software. Rather, Ireton merely refers to
conventional public-private key encryption techniques, which, at best,
indicates that the private key is used in the traditional sense to access or
decrypt the encrypted digital files and the usage rights associated therewith.
See, e.g., Ex. 1010 ¶¶ 35 (disclosing that “conventional encryption or
encoding techniques” are employed to secure the communication
channel), 50 (disclosing that “conventional public-private key encryption
techniques” are used to encrypt the digital media).
We also agree with ContentGuard that, when attesting to the teachings
of Ireton, Dr. Prakash applies a new definition of “behavioral integrity” that
is different from the Board’s previous definition, the definition adopted by
the district court, and the definition adopted for purposes of this proceeding.
As we explained above, although Dr. Prakash acknowledges the Board’s
previous definition of “behavioral integrity” as requiring “software to
include a digital certificate in order to be installed in the repository”
(Ex. 1003 ¶ 284 (citing Ex. 1041, 13)), he nonetheless applies a new
definition for “behavioral integrity” when testifying that Ireton’s digital
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media servers 110a and 110b each constitute the claimed “repository.” The
relevant portion of Dr. Prakash’s testimony states that: “Ireton . . . shows
that it employs ‘a trusted system which maintains physical, communications
and behavioral integrity, and supports usage rights,’ where: . . . ‘behavioral
integrity’ means ‘trusted software within a repository that enables control of
content use.” Ex. 1003 ¶ 681.
Dr. Prakash does not explain why he deviated from the Board’s
previous definition of “behavioral integrity” (see, e.g., Ex. 1041, 13), which
eventually was adopted by the district court (Ex. 2001, 19–21) and adopted
for purposes of this proceeding (see supra Section A). Nor does Dr. Prakash
explain how his new definition of “behavioral integrity” would be
understood by one of ordinary skill in the art in light of the specification of
the ’280 patent. Absent some underlying facts or data to support Dr.
Prakash’s new definition of “behavioral integrity,” his testimony in this
regard is entitled to little, if any, weight. See 37 C.F.R. § 42.65 (“Expert
testimony that does not disclose the underlying facts or data on which the
opinion is based is entitled to little or no weight.”).
In summary, we are not persuaded that Apple has presented sufficient
evidence to support a finding that Ireton’s digital media servers 110a and
110b each constitute the claimed “repository” that exhibits “behavioral
integrity” because the private key used by these digital media servers to
access or decrypt the encrypted digital files, and the usage rights associated
therewith, does not constitute a digital certificate. Based on the record
before us, Apple has not demonstrated a reasonable likelihood that it will
prevail on its assertion that claims 1–5, 8, 11–16, 19, 22, 24–28, 31, and 34
would have been obvious over Ireton.
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C. Remaining Obviousness Grounds
Apple contends that claims 1–5, 8, 11–16, 19, 22, 24–28, 31, and 34
are unpatentable under § 103(a) over the following combinations: (1) the
combination of Ireton and England; and (2) the combination of Ireton and
Gruse. Pet. 45–60. In each of these asserted grounds based on obviousness,
Apple does not apply the teachings of England or Gruse in such a way that
remedies the deficiencies in Ireton discussed above. See generally id.
Therefore, for essentially the same reasons discussed above, Apple has not
demonstrated a reasonable likelihood that it will prevail on its assertion that
claims 1–5, 8, 11–16, 19, 22, 24–28, 31, and 34 would have been obvious
over the following combinations: (1) the combination of Ireton and
England; and (2) the combination of Ireton and Gruse.

III. CONCLUSION
Taking into account the arguments presented in ContentGuard’s
Preliminary Response, we conclude that the information presented in the
Petition does not establish that there is a reasonable likelihood that Apple
will prevail in challenging claims 1–5, 8, 11–16, 19, 22, 24–28, 31, and 34
of the ’280 patent as unpatentable under § 103(a).

IV. ORDER
In consideration of the foregoing, it is ORDERED that the Petition is
DENIED and no trial is instituted.
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For PETITIONER:
Jeffrey P. Kushan
Michael R. Franzinger
Sidley Austin LLP
iprnotices@sidley.com

For PATENT OWNER:
Timothy P. Maloney
Nicholas T. Peters
Fitch Even Tabin & Flannery LLP
tpmalo@fitcheven.com
ntpete@fitcheven.com

Robert A. Cote
McKool Smith, P.C.
rcote@mckoolsmith.com